In Refined Metals Corporation v. NL Industries Inc., 937 F.3d 928 (7th Cir. 2019) the U.S. Court of Appeals for the Seventh Circuit affirmed a lower court dismissal of a contribution action brought by a Potentially Responsible Party (PRP) 19 years after it had executed a settlement with federal and state environmental agencies. The court joined several other circuits in holding that a settlement resolving Resource Conservation and Recovery Act (RCRA) claims triggers the three-year statute of limitations for Comprehensive Environmental Response Compensation and Liability Act (CERCLA) contribution actions.
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